Colgate-Palmolive has a long standing policy against making contributions to political parties or candidates, which is set forth in both our Code of Conduct and our internal Business Practices Guidelines. These policies prohibit the use of Company resources for contributions to any political party or candidate, whether Federal, state or local. This prohibition covers not only direct contributions but also indirect assistance or support through buying tickets to political fundraising events, furnishing goods, services or equipment for political fundraising or other campaign purposes, volunteer work by Colgate-Palmolive people within normal business hours or the use of Colgate-Palmolive facilities for fundraising or political purposes. In addition, Colgate-Palmolive does not use corporate funds to support 527 organizations, 501(c)(4) organizations, ballot measures or “Super PACs.”
Similar to most multinational companies, Colgate-Palmolive belongs to trade and industry associations in the United States to which the Company pays annual dues. To help ensure that the trade associations do not use any portion of the dues or other funds paid by Colgate-Palmolive for political contributions, Colgate-Palmolive's Chief Ethics & Compliance Officer annually informs the U.S. trade associations of our policy prohibiting such contributions. In addition, the Company's Chief Ethics & Compliance Officer requests each U.S. trade association to which the Company pays in excess of $10,000 annually to certify: (i) whether any portion of Colgate-Palmolive’s dues or contributions are not deductible pursuant to Section 162(e)(1) of the Internal Revenue Code and, for any non-deductible amounts, to provide a breakdown of amounts spent under the categories set forth in Section 162(e)(1), and (ii) that no Colgate-Palmolive dues or contribution were spent directly or indirectly (e.g., through political action committees) in connection with any political campaign or in connection with any candidate for public office.
For the calendar year 2021, all the U.S. trade associations to which we pay dues or make other payments in excess of $10,000 annually have satisfied the Company's request for information regarding their non-deductible expenses and confirmed their compliance with our policy.
Colgate-Palmolive thanks Boston Common Management, whose concerns about the potential use of trade association dues for political parties or candidates prompted the Company to adopt this annual procedure.